PRIVACY POLICY

We at MUCH TRAVELS know that providing information online involves a lot of confidence on your part. We take this trust very seriously and we have, as a priority, to guarantee the security and protection of the personal data provided by our “Users” (or “You”) during their visits to our website or our application.

This Privacy Policy aims to provide clear and accurate information to our Users about the collection, use, storage and other types of treatment of their personal data carried out in the context of the provision of services, availability and management of our platforms, in addition to informing how the privacy of Users is protected in the course of our relationship with You.

1. TO WHICH THIS PRIVACY POLICY APPLIES

MUCH TRAVELS corresponds to the controller of personal data whose treatment is described in this Privacy Policy, treating them together with other controllers and operators, as described in this document.

Our Privacy Policy is applied to Users and other individuals who browse our website www.muchtravels.com.br/ and our application (“Platforms” or “Platform”), as well as the data provided by You when You create an account on the Platforms or in the cases of requesting a quote, hiring a package or service offered by MUCH TRAVELS, exchanging messages or other forms of contact with MUCH TRAVELS or in other situations in which you have contact with our services, such as browsing or doing any use of our Platform. Our Privacy Policy will also apply to personal data collected by MUCH TRAVELS automatically when You access our Platform (for example, your IP address, date and time).

Please note that this Privacy Policy will apply to data provided by You or your parents or legal guardians. In addition, this Policy will apply to individuals who enter into a contract with MUCH TRAVELS and to other passengers / travelers who take advantage of the services provided by Us. In any case, we comply with all applicable data protection laws that we operate.

This Privacy Policy does not apply to third party websites, even though You access them through links contained in our Platform. Third party websites are outside of our hosting environment and the information contained therein and collected by them is beyond our direct control. It is up to You to verify that you are in compliance with the third party’s Privacy Policies. This Privacy Policy will also not apply to data processing activities conducted by other service providers involved.

2. INFORMATION WE TREAT

MUCH TRAVELS may collect and process Users’ personal data for the purposes described in this Privacy Policy. The types of personal data that we will process throughout our relationship may include:

▪ Registration information. When you register, contact us or show interest in our services, you will initially provide us with some registration data, such as full name, identification document number, contact phone number, email address, date of birth, gender , address, among other identification data necessary for the provision of our services.

▪ Payment processing and bank information. We may work together with third party companies for managing online payments, financing, among others, to process purchases and purchases of products and services made by You through our Platform. In such cases, it is important that You are aware that such companies may collect and store your information and data, including bank details and credit card data, and perform credit and risk analysis.

▪ Information about other people. Through our Platform, if You hire a travel package for You and the companion (s), You must provide the necessary information so that MUCH TRAVELS can also provide the services for the companion. In this case, you must inform the other person who will share the personal data with MUCH TRAVELS, this treatment being subject to this Privacy Policy.

▪ Data of children and adolescents: We may also process data on children or adolescents for the provision of services. MUCH TRAVELS undertakes to treat such personal data in the best interest of the child or adolescent and exclusively for the performance of the contract. If the data provided is data from children, You, as legal guardian, consent, at the time of entering the data for contracting on the Platform, as expressly informed at such time, with the treatment of the child’s data, by MUCH TRAVELS, to allow the adequate provision of services under the contract.

▪ Supporting documentation in case of reimbursement or fine review. In the event of an event that prevents You from taking advantage of a service already contracted, You may need to share information and supporting documents regarding such occurrence, which may reveal sensitive data of your own or of third parties. Such documents may include, but are not limited to, health certificate, death certificate, birth certificate, among others, depending on the specific case. Any sensitive data will only be used to exercise rights under the contract entered into between MUCH TRAVELS and the Client, with no processing of such data for other purposes.

▪ Games, advertising and promotions. It will also be possible to collect your personal information when You participate in games, quizzes and other marketing actions promoted by Us on our Platform and on third party websites.

▪ Customer service. If you need to contact the Customer Service department or our Data Protection area, via chat, phone calls and / or e-mails, please be aware that we may collect the personal information necessary to complete your order and contact you you using the contact information for your account that You have provided, as well as collect information about your communications with our team.

▪ IP addresses, cookies and identifiers. When You visit or access our Platform, we may automatically collect certain information from your computer or mobile device, such as session data, IP address, Web browser software, the reference site, dates and times of User interactions with our Platform and geolocation. We may also collect information about your online activity, such as the content you view, the pages you visit and the surveys or reservations you make or do. One of our goals with which we collect this automatic information is to help us understand the interests and preferences of our Users, to personalize and improve their browsing experience on the Platform and to present some ads of interest to them.

As mentioned above, MUCH TRAVELS may use cookies when the User browses the Platform. Cookies are associated only with an anonymous User and his computer and do not provide references that allow us to deduce the User’s name and surnames. Thanks to cookies, it is possible for MUCH TRAVELS to recognize registered Users right after their registration, without having to log in for each visit. In addition, we may also allow third parties to collect information about your online activities through cookies and other technologies. Please note that we have no access to or control over cookies or other technologies that these third parties may use to collect information about your interests, and those third parties’ information management practices are not covered by this Privacy Policy. The User has the possibility to configure his browser to be notified of the receipt of cookies and to prevent the installation of cookies. Please consult your browser’s instructions and manuals to expand this information. In order to use the Platform, it is not necessary for the User to allow the installation of the cookies sent, but navigation and your experience may be impaired if You disable cookies from MUCH TRAVELS.

The personal data processed by us at MUCH TRAVELS may vary depending on the service or package of services contracted by the User and on specificities and preferences that the User may report or request.

In addition to the personal data mentioned above, we may receive from partners who are part of the provision of services (for example, airline, hotel, car rental, etc.) information about the status of the trip, stay and consumption details at the accommodation for purposes payment processing. Third party websites accessible from the Platform are under the responsibility of third parties. MUCH TRAVELS will not be responsible for ordering and / or providing personal data on third party websites. We recommend that You consult the respective privacy policies of such websites to be properly informed about the use of your personal data by other websites or other tools.

3. HOW WE COLLECT INFORMATION

Through our Platform, You will be able to browse the options of packages and separate services offered or intermediated by MUCH TRAVELS, whether or not registered on the Platform. Mere navigation, regardless of registration or contracting by the Platform, may give rise to the collection of navigation information, as mentioned above.

In addition to browsing, We may collect your personal data if You register with our Platform, creating an access login and, even if You purchase a package or hire the separate services intermediated by Us.

If You initiate a transaction through the Platform, we may receive information about You from service providers that are part of payment processing and fraud analysis. In addition, as mentioned,

the suppliers activated to provide the services to the Users, under the terms of the contract signed with the User, will be able to share with us data on the progress of the trip and its consumption during the provision of services. In all cases, We are committed to keeping all data in absolute confidentiality, treating only the personal data necessary to provide the services, comply with any legal obligation or, in other cases permitted by law.

The User will be informed whenever we consider the provision of any personal data mandatory. If the User refuses to provide these mandatory data, it will not be possible to continue contracting and providing services. In this case, MUCH TRAVELS reserves the right not to enter into a contract with the User, since such data is necessary for this purpose.

4. FOR WHAT PURPOSE WE TREAT YOUR INFORMATION

We will treat your information and personal data for the following purposes:

▪ User Registration on the Platform;

▪ Credit and fraud analysis, in accordance with our policies, and consultation on the User’s ability to pay;

▪ Formalization of the service intermediation contract with the User;

▪ Processing of financial transactions and collection of defaulters;

▪ Intermediation of the User relationship with the suppliers necessary for the provision of services (for example, hotels, airlines, car rental companies, parks, among others, depending on the specific case) and making payment to such suppliers;

▪ Analysis of requests for reimbursement, review of fines and occurrences of no-shows;

▪ Analysis of fraud, chargeback and chargeback occurrences on the credit card;

▪ Sending communication to Users with information about the progress of requests, logistics processes, as well as other relevant information about the contracted service or about the Platform;

▪ Sending marketing communications by e-mail or SMS and carrying out other marketing actions, including targeted marketing, to promote MUCH TRAVELS and the other companies in the group;

▪ After-sales service to assist in the purchase of seats, luggage, change of dates, among others;

▪ Dealing with doubts, complaints or suggestions sent through customer service channels;

▪ Control of MUCH TRAVELS performance, improvement of MUCH TRAVELS commercial and promotional initiatives and improvement of the User experience;

▪ Analysis of the User profile to improve offers and target content, ads and personalized products that may interest the User.

5. WITH WHOM WE SHARE YOUR INFORMATION

As you know, MUCH TRAVELS intermediates services between Users and countless suppliers from different branches with whom we have partnerships. Such suppliers can be airlines, car rental companies, hotels around the world, amusement parks, companies that provide services for receiving and directing the User at the location of the trip, among others. Thus, We may share your personal information with these third parties or other business partners necessary for the purpose of providing the services. This sharing occurs with the following partners, based on the following criteria and for the following purposes:

▪ Companies that operate the call center and other service channels so that the attendants can assist You;

▪ Credit bureaus and anti-fraud analysis companies for the purposes of credit analysis and fraud verification at the time of contracting the package;

▪ Service providers for the purpose of providing software and other information technology systems that assist in the provision of services and management of Users;

▪ Suppliers necessary for the provision of services, such as hotels, airlines and car rental companies, depending on the package contracted by You. There is an intense sharing of data with such suppliers that is essential to enable the execution of the contract between Us and the User. The User is aware that We may share sensitive data with such suppliers in the event of a refund request or fine review and that such sharing is necessary for the regular exercise of rights under the contract entered into with MUCH TRAVELS. In some cases, we may also share your payment details so that the airline can process the transaction;

▪ Value-added service providers that the User may purchase when entering into a contract with MUCH TRAVELS (for example, travel insurance);

▪ Social networks for targeted marketing purposes.

In addition to the above providers, it is possible that MUCH TRAVELS uses third party service providers to help offer its own services. In this case, such providers will have no decision-making power over personal information that they process on our behalf.

We may also share User’s personal data with third parties (including government agencies) in order to respond to investigations, legal actions, lawsuits or to investigate, prevent or take action on illegal activities, suspected fraud or situations involving threats potential physical security of any person or if otherwise required by law.

If MUCH TRAVELS is involved in a merger, acquisition or sale of all or part of its assets, the User’s personal data may be shared with the acquiring company or person. In circumstances in which the identity of the controller of personal data changes as a result of any transaction, the User will be notified of any choices he may have about his personal data.

MUCH TRAVELS may share certain non-personal information (anonymized data, which does not identify our Users individually) with third party service providers, trusted partners or approved researchers, in order to better understand which advertisements and services may be of interest to you, in order to improve quality and the general effectiveness of our services or the services of our partners, or to contribute to academic research.

6. TRANSFERS OF INFORMATION OUTSIDE BRAZIL

We may transfer personal data from Users to service providers located abroad, including cloud service providers. If you purchase travel packages to destinations outside of the country, it will be necessary to transfer your personal data so that suppliers can provide such services. When the User’s personal data is transferred outside of Brazil, We will take appropriate measures to ensure adequate protection of their personal data in accordance with the requirements of the applicable data protection legislation.

7. HOW LONG DO WE WITHDRAW YOUR INFORMATION

MUCH TRAVELS strives to ensure that personal data is kept as up to date as possible and that unnecessary or excessive data is deleted or made anonymous whenever and as soon as possible.

In general, the User’s personal data will be retained for the time necessary to satisfy the purpose for which it was collected. When the User contracts a service or package through the Platform, this will, as a rule, be the period corresponding to the signing of the contract with MUCH TRAVELS until the end of the contracted trip. In addition, We may retain the User’s personal data for the period corresponding to the duration of any applicable statutory limitation period after the end of the relationship with the User. Thus, we may store and maintain the User’s personal information and data as long as there is a relationship / link with the User, to comply with legal obligations or for the time necessary to preserve our legitimate interests.

The end of the treatment of the User’s personal data will occur when it is verified:

▪ That the purpose for which the personal data was collected has been achieved or that the personal data collected is no longer necessary or relevant to achieve the specific purpose desired;

▪ A manifestation by the User in this regard, especially for cases in which We receive the User’s consent for certain processing of personal data, if any; or

▪ In case of legal determination.

In such cases, except for the hypotheses established by the applicable legislation or by this Privacy Policy, the personal data will be eliminated or anonymized so that the data completely lose the ability to identify the original data holder.

8. THE RIGHTS OF THE USER AS THE HOLDER OF PERSONAL DATA

The User will have certain rights in relation to his personal data, as established by the legislation applicable to the protection of personal data. Such rights include, but are not limited to:

▪ Confirmation of the existence of personal data processing. Upon request and proof of identity, MUCH TRAVELS will grant the User the confirmation of the existence of personal data processing, under the terms of the applicable legislation;

▪ Access to personal data. Upon proof of his identity, the User may request access to his personal data collected and stored by Us. When the treatment is justified in the User’s consent or in the execution of a contract, the User may also request a full electronic copy of his data personal data in a format that allows their subsequent use;

▪ Correction of incomplete, inaccurate or outdated data. We are interested in keeping the personal data we process accurate and up-to-date, so that we will update and correct the data at the request of the Client, after the proper validation of the Client’s identity. The User is also responsible for ensuring that changes in personal circumstances are notified to MUCH TRAVELS;

▪ Information on shared use of data. Information on the sharing of personal data can be found in this Privacy Policy. MUCH TRAVELS is available to the User for further clarification;

▪ Elimination of personal data. The User may request the elimination of personal data that has been collected by Us from his consent, at any time, by means of free and facilitated manifestation. The elimination of personal data can only be complete for personal data that are not necessary for MUCH TRAVELS to comply with legal, contractual obligations, to protect its legitimate interest and in other cases admitted legally;

▪ Revocation of consent. The User may revoke any consent that he has given for the treatment of his personal data for certain purposes (if there is in fact treatment of personal data based on consent), at any time, by means of a free and facilitated manifestation. It is important to inform that the treatments carried out prior to the revocation of consent are ratified and that the request for revocation will not imply the elimination of previously processed personal data and that are maintained by Us based on other legal grounds;

▪ Data portability. The User has the right to request that his personal data be transferred to another service provider, which must be done in a structured format, commonly used and machine-readable, as technically feasible and in accordance with any regulations on the subject;

▪ Elimination, opposition, anonymization or blocking of personal data. In cases where the User does not agree with the treatment and understands that MUCH TRAVELS may be processing some data that are not necessary or that otherwise do not meet the requirements of the applicable legislation, the User will have the right to object to the treatment or request the anonymization, deletion or blocking of your personal data, unless MUCH TRAVELS has legitimate reasons for the treatment;

▪ Automated decision review. The User has the right to request a review of any decisions that affect his interests, including decisions aimed at defining his personal, professional, consumer and credit profile or aspects of his personality taken solely by a computer or other automated process. . The User may also request information on the criteria and procedures used in the context of this decision, within the limits accepted by the applicable legislation;

▪ Complaint to the Authority. The User has the right to submit a complaint to the National Data Protection Authority – ANPD or to another competent body if he considers that the treatment of his personal data violates any provision of the applicable law.

For more information about the User Rights or to exercise any of these rights, the User can contact the MUCH TRAVELS Data Protection team through the email info@muchtravels.com.br. Before starting to process your request, MUCH TRAVELS may request more information about the User for the purpose of authenticating his identity, thus ensuring that we will only share information with the User himself or with someone who has powers to represent him.

9. PROTECTION OF PERSONAL INFORMATION AND DATA

MUCH TRAVELS treats the information and personal data of Users with a high level of protection, confidentiality and care, using appropriate technical and organizational measures to protect personal data against unauthorized or illegal treatment, against accidental loss, destruction or damage, acting in a responsible and ethical manner, respecting the terms of the laws and regulations applicable to data privacy.

10. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is a dynamic tool and may be updated periodically to ensure that the information provided is in accordance with data protection laws. Accordingly, MUCH TRAVELS reserves the right to change this Privacy Policy at any time, by publishing the updated version at the address of our Platform. In the event of material changes to the Privacy Policy, the User may receive a notice in this regard or be communicated through the official channels of communication.

This Privacy Policy was updated and revised in May 2021.

11. CONTACT INFORMATION

MUCH TRAVELS, registered at CNPJ / MF under number 33.561.495 / 0001-87, with headquarters at Rua Dr. Francisco Prestes Maia, 254 – Jardim Paulistano, Sorocaba – SP, CEP: 18040-650, here called MUCH TRAVELS is controller of the personal data of the Users as the User accesses our Platform and / or performs the contracting of our services.

Matters related to this User Privacy Policy or other matters relating to the protection of personal data should be addressed – to the Data Protection Officer / Person in charge of handling personal data through the email info@muchtravels.com.br.

Graciously,

MUCH TRAVELS Team

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